In external review
With counsel
3
1 overdue
Comments to consolidate
5
across 2 documents
Time with counsel
3.2 d
median
Agent flags confirmed
81%
by counsel, last 90 days
Q3 Investor Update
Dana Sultan · IR · UAE, UK, Singapore
Agent markup
against rule sets
With counsel
first reviewer
Consolidation
agent merges comments
Internal review
Legal & Compliance
Decision
approve or return
Back to sender
in Compass
Counsel
Simpson Thacher
Sent
16 Sept
Due back
19 Sept
Round
1 of 1
Counsel comments, consolidated by the agent
4 items| Passage | Agent flag | Counsel | Match |
|---|---|---|---|
| “18.4% over the last twelve months” | Past-performance warning missing | Agree — add the FCA-form warning directly after the figure • Comment box | Agrees |
| “guaranteed returns across the cycle” | Prohibited wording | Agree — remove entirely, no rewording will cure it • Marked-up upload | Agrees |
| “at least two exits” | Forward-looking without qualifier | Disagree for UAE; required for UK and Singapore only | Partly |
| Disclaimer, page 14 | — | Add: not for distribution in the United States • Marked-up upload | New |
Activity
16 Sept 10:12Agent marked up 5 passages against UAE, UK, SG rule sets
16 Sept 10:20Link sent to Simpson Thacher
17 Sept 15:03Link opened
18 Sept 09:41Comments received — 2 via comment box, 1 by email, 1 marked-up file